Personal Data Processing Policy1. General terms and conditionsThis Personal data processing Policy is made in accordance with the requirements of the Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (further referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Advantage Accountants and Advisors Pty Ltd (further referred to as the Operator).1.1. The Operator considers as his/her most important aim and and the condition for the implementation of activities the fulfilment of the rights and freedoms of a person and citizen in the processing of their personal data, including the protection of the privacy rights, as well as personal and family secrets.1.2. Current policy set by Operator regarding the personal data processing (further referred to as the Policy) applies to all information that Operator can receive about website visitors https://advantage.accountants.2. Main terms used in the Policy2.1. Automated processing of personal data is the personal data processing using computer technology.2.2. Blocking of personal data is temporary termination of personal data processing (except in cases where processing is necessary to clarify personal data).2.3. Website is a set of graphic and informational materials, as well as computer programs and databases that ensure the former’s availability on the Internet at the following network address https://advantage.accountants.2.4. Personal data information system is a set of personal data contained in databases, as well as information technologies and technical means that ensure their processing.2.5. Depersonalization of personal data consists of actions leading to the impossibility of linking without the use of additional information the personal data to a specific User or other personal data owner.2.6. Processing of personal data involves any action (operation) or a set of actions (operations) performed on personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.2.7. Operator is a state or municipal body, legal entity or individual, independently or jointly with other persons arranging and (or) processing personal data, as well as determining the purposes of processing personal data, the scope of personal data to be processed, and actions (operations) to be performed on personal data.2.8. Personal data consists of any information related directly or indirectly to a specific or identifiable User of the Website https://advantage.accountants.2.9. Personal data authorized by a personal data owner for distribution is the personal data to which an unlimited number of persons have been given acce by the personal data owner by the means of his/her giving consent to the processing of personal data and its distribution in accordance with the procedure provided for by the Law on Personal Data (futher referred to as personal data authorized for distribution).2.10. User is any visitor of the website https://advantage.accountants.2.11. Provision of personal data means a set of actions aimed at disclosure of personal data to a certain person or a certain number of persons.2.12. Distribution of personal data means actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization with personal data of an unlimited number of persons, including publication of personal data in the media, its appearaance in information and telecommunications networks or provision of access to personal data in any other way.2.13. International personal data transfer is a transfer of personal data to the territory of a foreign state, within the authority of a foreign state, to a foreign individual or a foreign legal entity.2.14. Destruction of personal data involves any actions that leads to personal data being permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data.3. Basic rights and obligations of the Operator3.1. The Operator has the right to:– receive reliable information and/or documents containing personal data from a personal data owner;– if the owner of personal data withdraws consent to the personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data owner if there are grounds for it specified in the Personal Data Law;– independently determine the set and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts approved in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.3.2. The Operator is under obligation to: – provide the personal data owner, at his/her request, with information concerning the processing of his/her personal data;– arrange the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;– respond to requests and applications from personal data owners and their legal representatives in accordance with the requirements of the Personal Data Law;–send to the authorized body responsible for the protection of the personal data owners’ rights the necessary information at its request within 30 days from the date of receipt of such request;– publish or otherwise provide unrestricted access to the current Policy regarding the processing of personal data;– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions with regard to personal data;– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the order and cases procured by the Personal Data Law;– perform other duties provided for by the Personal Data Law.4. Basic rights and liabilities of personal data owners4.1. Personal data owners have a right to:– receive information concerning the processing of his/her personal data, except in cases mentioned in the federal laws. The information is provided to the personal data owner by the Operator in an accessible form, and it should not contain personal data related to other personal data owners, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is defined by the Personal Data Law;– ask the operator to clarify his/her personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect his/her personal rights;– suggest the terms of preliminary consent when personal data is processed to promote goods, works and services on the market;– revoke consent to the personal data processing;– appeal to the authorized body for the protection of personal data owners’ rights or in court against illegal actions or inaction of the Operator when processing his/her personal data;– exercise other rights determined by the legislation of the Russian Federation.4.2. Personal data owners are obliged to:– provide the Operator with reliable data about themselves;– inform the Operator about the new details in (update or change) their personal data.4.3. Persons who have provided the Operator with false information about themselves or information about another personal data owner without the latter's consent are legally responsible in accordance with the legislation of the Russian Federation.5. The Operator may process the following personal data of the User5.1. Surname, first name, patronymic.5.2. Email address.5.3. Phone numbers.5.4. Additionally, the collection and processing of anonymous data about visitors is going on the website (including “cookie” files) using the Internet statistics (Yandex Metric and Google Analytics and others).5.5. The above data, when further referred to in the text of the Policy, are used under the umbrella concept of Personal Data.5.6. Processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life shall not be carried out by the Operator.5.7. Processing of personal data allowed for distribution that is part of the special personal data categories specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in the Article 10.1 of the Personal Data Law are observed.5.8. The User's consent to the personal data processing allowed for distribution is issued separately from other consents to the processing of his/her personal data. At the same time, the terms stipulated, in particular, by the Article 10.1 of the Personal Data Law are to be observed. The requirements for the exact content of such consent are established by the authorized body for the protection of the personal data owners’ rights.5.8.1. The user provides consent to the processing of personal data authorized for distribution directly to the Operator.5.8.2. It is no later than three business days from the date of receipt of the User's consent, that the Operator is obliged to publish information on the processing terms, on the availability of prohibitions and terms for processing of personal data allowed for distribution by an unlimited number of persons.5.8.3. The transfer (distribution, provision, access) of personal data authorized by the personal data owner for distribution shall be terminated at any time at the request of the personal data owner. This request shall include the surname, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data owner, as well as a list of personal data to become the subject of processing termination. The personal data specified in this request can only be processed by the Operator whom it is sent to.5.8.4. Consent to the processing of personal data allowed for distribution shall be terminated upon receipt by the Operator of the request specified in the clause 5.8.3 of this Policy regarding the personal data processing.6. Principles of personal data processing6.1. The processing of personal data is to be carried out legally and fairly.6.2. The processing of personal data is to be limited to the achievement of specific, predetermined and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is forbidden.6.3. It is forbidden to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.6.4. Only personal data that meets the purposes of its processing is to be subjected to it.6.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The excessive quantity of the processed personal data in relation to the stated purposes of their processing is forbidden.6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing is ensured. The Operator shall take all necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.6.7. The storage of personal data is carried out in a form that allows determining the personal data owner within the period that does not last longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, or an agreement where the personal data owner is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.7. Purposes of personal data processing7.1. The purpose of processing the User's personal data:– informing the User by sending emails;– creation, execution and termination of civil law agreements;– providing the User with access to the services, information and/or materials contained on the website https://advantage.accountants.7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator via office@advantage.accountants with a notice “Refusal to receive notifications about new products and services and special offers”.7.3. Depersonalized User data collected using the Internet statistics services are used to collect information about User actions on the website, improve its quality and content.8. Legal grounds for processing personal data8.1. The legal grounds for processing personal data by the Operator are:– agreements made between the operator and the personal data owner;– federal laws and other regulatory legal acts in the realm of personal data protection;– users' consent to the processing of their personal data, meaning the processing of personal data allowed for distribution.8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms inserted in the website’s page https://advantage.accountants or sent to the Operator via e-mail. The User agrees with this Policy by filling out the appropriate forms and/or sending their personal data to the Operator. 8.3. The Operator processes depersonalized data about the User if it has been allowed in the User's browser settings (the saving of cookies and the use of JavaScript technology have been enabled).8.4. The personal data owner independently decides on the provision of his/her personal data and gives consent freely, out of his/her own accord and in his/her own interest.9. Terms of personal data processing9.1. The processing of personal data is carried out with the consent of the personal data owner to the processing of his/her personal data.9.2. The processing of personal data is necessary to achieve the goals stipulated by an international agreement of the Russian Federation or a law, as well as to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official that are subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.9.4. The processing of personal data is necessary for the execution of an agreement where personal data owner is a party, beneficiary or guarantor, as well as for the making of an agreement on the initiative of the personal data owner or an agreement under which the personal data owner will be a beneficiary or guarantor.9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data owner are not violated.9.6. Only the processing of personal data, access to which of an unlimited number of persons is provided by the personal data owner or at his/her request (further referred to as publicly available personal data) is carried out.9.7. Processing of personal data shall be carried out subject to publication or mandatory disclosure in accordance with federal law.10. Procedure for collection, storage, transfer and other types of personal data processingThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures that are necessary in order to comply with the requirements of the current legislation within personal data protection realm.10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to the personal data by unauthorized persons.10.2. The User's personal data will never, under any circumstances, be transferred to the third parties, except in cases related to the implementation of current legislation or when personal data owner has given his/her consent to the Operator to transfer data to a third party to fulfill obligations under a civil agreement.10.3. If the User finds any inaccuracy in the personal data, he/she can update it independently by sending a notification to the Operator's email address office@advantage.accountants with a notice “Personal data update”.10.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data had been collected, unless another period was indicated in the agreement or current legislation.The User can withdraw his/her consent to the processing of personal data at any time by sending a notification to the Operator's e-mail address office@advantage.accountants with a notice “Withdrawal of consent to the personal data processing”.10.5. All information collected by the external services, including payment systems, communication channels and other service providers, shall be stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data owner and/or the User has to familiarize themselves with these documents on time. The Operator is not responsible for the actions of external actors, including the service providers specified in this paragraph.10.6. The prohibitions established by the personal data owner on the transfer (except for providing access), as well as on the processing or processing terms (except for obtaining access) of personal data permitted for distribution, shall not be applied in cases of processing of personal data in the state, public and other public interests defined by the legislation of the Russian Federation.10.7. The Operator ensures the confidentiality of personal data when processing personal data.10.8. The Operator stores personal data in a form that allows determining the personal data owner, for the period that is no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, or an agreement where the personal data owner is a party, beneficiary or guarantor.10.9. The period for the termination of personal data processing may be defined by the achievement of the purposes of personal data processing, the expiration of the consent given by the personal data owner or the withdrawal of consent by the personal data owner, as well as the identification of unlawful personal data processing.11. List of actions performed by the Operator with the collected personal data11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.11.2. The Operator performs automated processing of personal data with or without collecting and/or transmitting the received information via information and telecommunication networks.12. International transfer of personal data12.1. Before the start of the international transfer of personal data, the Operator is obliged to ascertain that the foreign state where the transfer of personal data is supposed to be carried out provides reliable protection of the personal data owners’ rights.12.2. International transfer of personal data on the territory of foreign states that fails to meet the above requirements may be carried out only if there is written consent by the personal data owner to international transfer of his/her personal data and/or execution of the agreement where the personal data owner is a party.13. Confidentiality of personal dataThe operator and other persons who have gained access to personal data shall not disclose and distribute personal data to any third parties without the consent of the personal data owner, unless otherwise provided by federal law.14. Final provisions14.1. The User can receive any clarifications on issues of interest concerning the processing of his/her personal data by contacting the Operator via e-mail office@advantage.accountants.14.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid until it is replaced by a new version.14.3. The current version of the Policy is freely available on the Internet at https://advantage.accountants/privacy_policy.